Archive for the ‘significant submissions’ Category

A compelling challenge to South Australia’s sham Nuclear Fuel Chain Royal Commission

May 4, 2016
submission good
The proposal is that we should accept waste before the repository has been completely built and tested. This proposal is so reckless, as to be negligent. We would face the very real risk of being left with high-level nuclear waste, and no technology to properly handle it.
The plan [outlined in The Nuclear Fuel Cycle Royal Commission’s Tentative Findings] seems extraordinary. It is proposed that we should give ourselves a waste problem in the hope that we, unlike everyone else, could solve it – like a person who takes up smoking just to prove they can quit.

Response to the Nuclear Fuel Cycle Royal Commission’s Tentative Findings By Dr Andrew Allison, B.Sc. B.Eng. PhD. (Elec. Eng.) 17 March 2016

INTRODUCTION One of the Key Tentative Findings of the Nuclear Fuel Cycle Royal Commission is that: “The storage and disposal of used nuclear fuel in South Australia is likely to deliver substantial economic benefits to the South Australian community. An integrated storage and disposal facility would be commercially viable and the storage facility could be operational in the late 2020s.” [1]
I argue that this finding is open to challenge on technical, and economic grounds. I point out that no country has yet successfully operated a permanent high-level nuclear waste storage facility, without incident, for any substantial length of time. This includes technologically advanced nuclear nations, such as the USA, and Russia. These countries have been generating nuclear waste for over fifty years and yet they have still not solved the waste storage problem. It is stretching credibility to the limit to imagine that a non-nuclear country, like Australia, could succeed where the USA and Russia have failed.
No country has ever operated a high-level nuclear waste storage facility, as a commercial enterprise. It is doubtful that anybody ever will, because the service is impossible to price. No markets exist for this type of service. …….
WASTE DISPOSAL TECHNOLOGY IS STILL EXPERIMENTAL At the Media Conference on 15th February 2016 for the release of the “Tentative Findings” Report, Commissioner Kevin Scarce stated, “We’ve had waste now for 50, 60 years. There has not been an international solution yet.” It is difficult to reconcile this admission, with the advocacy of a nuclear waste repository in South Australia. ……
THE NUCLEAR FUEL “CYCLE” IS INCOMPLETE The basic problem, with the concept of a
nuclear fuel “cycle” is the segments have not yet been joined up to form an actual cycle. The global capacity for reprocessing is inadequate. Many nuclear countries are not reprocessing at all. This means that spent fuel is piling up as waste. This compounds the problem with waste disposal, which is also inadequate. …….. For over fifty years, most nuclear material has moved on a one-way journey from mines, through reactors, to temporary storage facilities. The fraction of material that has been bred, reprocessed, and then used as fuel is very small. It is misleading to call the chain of transformations a “cycle” until more technology has been developed……..
THE PROPOSAL FOR AN INTERIM STORE IS COMPLETELY NEGLIGENT The most alarming part of the Tentative Findings is in section 89, where an “interim store” is proposed: “imports of used fuel with interim storage and associated revenues commencing at year 11 after the project decision”.
The proposal is that we should accept waste before the repository has been completely built and tested. This proposal is so reckless, as to be negligent. We would face the very real risk of being left with high-level nuclear waste, and no technology to properly handle it
I am amazed that a government would even entertain such an outrageous proposal. We live in an era where it is argued that governments cannot operate, power utilities, water distribution, trains, bus services, banks, and communications services. At the same time, it is being proposed that the government of South Australia, alone in the history of the world, can acquire the expertise to operate a successful nuclear waste storage facility, and we are so confident of the ability of the government that we don’t even have to wait for the facility to be completed and tested, before accepting high-level nuclear waste. This seems to be extremely contradictory, and risky, to me.
ECONOMIC BENEFITS ARE UNCERTAIN AND MAY NOT BE WELL DISTRIBUTED Jacobs [5] published a disclaimer on their work which states: “In no part of this report does Jacobs, either explicitly or implicitly, make any recommendation or endorsement of the viability or otherwise of the Project.” Despite this, the “Tentative Findings” Report proposes a nuclear waste case using cost estimates that Jacobs say “are conceptual in nature” and that “… should only be regarded as no better than -50% to +100%”. This is a major contradiction. In my view, the pricing of commercial nuclear waste disposal is very speculative.
There is no marketplace for the international transfer of liability for high level waste. There is no known price that can be confidently used in a business case analysis. These points are all admitted in the “Tentative Findings” of the Royal Commission. There is no overseas commitment to the price used in the Jacobs’ analysis. The pricing is completely speculative. ……
This highlights a basic contradiction of the proposal. If the technology works then South Australia will face competition in a competitive market. If the technology does not work then South Australia may well be left with waste, and no means of storing it safely.
CONCLUSION The “Tentative Findings” Report proposes establishing a high-level international nuclear waste dump in South Australia. At best, this proposal seems to be reckless. We should not become an early adopter of this experimental and hazardous technology.
No prudent government should force these risks, associated with highlevel nuclear waste, onto their people, in perpetuity, merely in the pursuit of uncertain short-term financial gain.
To paraphrase Richard Dennis, of the Australia Institute: Australia is a lucky country, without any high-level nuclear waste. The plan [outlined in The Nuclear Fuel Cycle Royal Commission’s Tentative Findings] seems extraordinary. It is proposed that we should give ourselves a waste problem in the hope that we, unlike everyone else, could solve it – like a person who takes up smoking just to prove they can quit. [3]……

9 April: S Australia Nuclear Fuel Chain Royal Commission practically ignores waste transport dangers

April 9, 2016

ship radiation

As the days get a bit closer to #NuclearCommissionSAust’s announcement of its (predetermined) findings, we need to remember that the Commission’s “Issues Papers” almost completely ignored the question of the dangers of transporting highly radioactive trash across land and sea.

Paul Langley, in his fine response to the Commission’s “Tentative Findings”  raised this very important matter – in the extract below

Response to the Tentative Findings of the SA Nuclear Fuel Cycle Royal Commission A Submission by Paul Langley Nuclear Exhaust 16 Mar 16  “……Transport of HLNW from around the world to a SA HLNW geologic repository

The Royal Commission apparently assumes that the movements of many hundreds of thousands of tonnes of spent nuclear fuel from many countries around the world to the Gawler Craton will be low risk, no problems and perfectly safe. As contradictory as those stances are. I do not accept that position of default safety. Further I do not accept that the unloading of the HLNW will be perfectly safe. I do not accept that road transport from port to repository site will be perfectly safe, even on a dedicated purpose built road.

I would recommend that Super Freighters laden with the contents of countless reactor cores not sail down the Somali coast nor in the waters to the south of Thailand for fear of pirates. They should avoid man made Islands in the South China Sea. I suppose the ships will be guarded by 6 English policemen each with two revolvers between them. Rather than half the Pacific Fleet they would actually warrant. If they ever get to leave their home ports.  What is the Somali coast going to be like in 40 years? Peaceful or short of rad weapons?…….”

6 April Today’s scrutiny on #NuclearCommissionSAust

April 6, 2016

graph S Aust waste dump costs

It’s one month until the South Australian Nuclear Fuel Chain Royal Commission will announce its findings. And everyone knows what they will be  – “nuclear waste importing will be a bonanza for South Australia”

This is the first of the significant posts that will appear on this site each day, ,until 6th May.

Kevin Scarce has dismissed opposition to the plan as largely “emotional”, not “factual” . I suspect that will be the way in which the Commission will deal with the opposing Submissions.  Here’s today’s:

The Greens SA’s submission to the Nuclear Royal Commission’s Tentative Findings rejects the suggestion that an economic bonanza awaits our State if South Australians would only resign ourselves to becoming the world’s nuclear garbage bin.

“The Royal Commission has been blinded by imaginary wealth and sucked into believing that a project that has never succeeded anywhere else in the World is South Australia’s for the taking”, said Greens SA Parliamentary Leader, Mark Parnell MLC.

“The most obvious question is being ignored: If this is such a great deal, how come no other country has grabbed it before now?

“The Greens are urging the Royal Commission to “get real” and critically examine the supposed economic benefits alongside the ongoing economic, social, environmental and reputational costs.

“Washing your hands of responsibility for a toxic legacy left to future generations is just immoral.

“The solution to South Australia’s current unemployment problems won’t be solved with mythical jobs that are decades into the future with the creation of toxic liabilities that last hundreds of thousands of year.

On releasing the “Tentative Findings” Report to the media on 15th February 2016, Commissioner Kevin Scarce stated, “The community needs to understand the risks and the benefits.”  The Royal Commission’s “Tentative Findings” highlights many purported benefits but is scant on detail when it comes to the profound risks.

According to the Greens’ submission, the “Tentative Findings” suffer from:
1.Unrealistic expectations of the magnitude of the project;
2.Failure to appreciate 6 decades of international failure to solve the nuclear waste problem;
3.Missing costs, unfunded liabilities, missing contingencies and failure to recognise inevitable cost blow-outs
4.Heroic assumptions of other countries’ willingness to pay for SA to take their nuclear waste;
5.Lack of recognition of the potential for irrecoverable sunk costs and unlimited future liabilities;
6.Failure to address reputational damage and impact on other sectors of the economy; and
7.Naïve expectations that South Australia would get to keep all the profits from a nuclear waste dump in our State, without having to share them with other States.

“The Commission’s final report due on 6th May should recommend that the folly of South Australia’s increased involvement in the nuclear industry be abandoned.

“In relation to the other Terms of Reference, increased uranium mining, uranium processing or nuclear power were never really an option for SA and the Royal Commission was an expensive way to tell us what we already knew”, concluded Mark Parnell.